Pitfalls in pharmacy and prescribing clinic partnerships

Shahzad Ahmad, Legal & Clinical Governance expert, outlines how pharmacies can mitigate compliance risks and protect patient safety while collaborating with prescribing clinics

Prescribing in pharmacies is an emerging opportunity, and I’m passionate about supporting proper governance arrangements for businesses. But does the governance and administrative burden reduce if your business is not doing the prescribing?

Recently, I’ve come across several independent pharmacy businesses across the UK who have been approached by prescribing clinics to dispense medicines for their patients. While these partnerships can present lucrative opportunities, they also come with significant responsibilities and potential risks. Pharmacy owners and superintendent pharmacists must be fully aware of the guidance set by the General Pharmaceutical Council (GPhC) and ensure that all requisite checks are performed to maintain compliance and safeguard patient safety.

The growing trend of prescribing clinic collaborations

For one reason or another, private prescribing clinics are sprouting up all over the place, offering specialised services such as weight management, hormone therapy, or dermatological treatments. These are quickly becoming a prominent feature in our healthcare landscape. Many of these clinics lack in-house dispensing capabilities, leading them to seek partnerships with pharmacies to satisfy a growing number of consumers. In the current economic climate, these collaborations can offer a new revenue stream and an expanded patient base. However, with these opportunities come responsibilities that must not be overlooked.

Understanding the GPhC guidance

During my time as a GPhC inspector between 2015 and 2020, I was fortunate enough to have an insight into the regulatory challenges (and gaps) that the GPhC and other regulators had to contend with. It is with this lens that I look at particular guidance pieces such as the GPhC guidance for registered pharmacies providing services at a distance, including on the Internet (March 2022).

Despite the lengthy title, it is the above guidance that pharmacies should be cognisant of before getting into bed with any prospective partner. The GPhC has established this guideline to ensure that pharmacies maintain high standards of practice, ‘whether or not the prescribing service is owned and operated by you or a third-party business’.

Among other things, pharmacies are required to:

1. Ensure the clinical appropriateness of prescriptions: This includes verifying that the prescribed medication is suitable for the patient’s condition, taking in consideration the patient’s medical history and how continuity of care can be maintained.
2. Assess the compliance of prescribing clinics: Pharmacies must ensure that the prescribers they are working with are appropriately registered, insured and competent. This involves checking that the prescriber is registered with a relevant professional body, such as the General Medical Council (GMC)
3. Maintain clear communication: There should be clear and ongoing communication between the pharmacy and the prescribing clinic. Any concerns about a prescription should be promptly discussed with the prescriber before the medication is dispensed and supplied. Documentation of these communications is also crucial for legal and regulatory purposes. After considering relevant factors, pharmacies should not be afraid to refuse to dispense a prescription if there are significant concerns.

Common pitfalls and how to avoid them

Despite these clear guidelines, some pharmacies have found themselves in breach of GPhC guidance and standards, often due to inadequate checks or a lack of understanding of their responsibilities. As well as impacting the registration of your pharmacy, it can have a fitness to practice impact on individuals too.

Some common pitfalls and strategies to avoid them:

1. Lack of preparation: Going into an arrangement without adequate risk assessments, understanding of regulatory guidance and in-depth knowledge of the prescribing provider. Do your due diligence of how the service works, because the pharmacy is responsible too.
2. Failure to audit: Some pharmacies may not rigorously check the credentials of the prescribing clinic or its practitioners. They may not check the prescribing process and how the service ensures that the prescriptions it generates are safe and appropriate (including the identity verification). It is necessary to audit practice regularly to ensure compliance with best practice guidance and to address any concerns.
3. Lack of oversight and monitoring: In some cases, pharmacists may overlook the need to contact prescribers with questions or concerns. However, open communication is essential to ensure patient safety. The prescription and monitoring of chronic medicines may need particular attention, as it could be possible that patients are obtaining these medicines from other sources too.

The importance of ongoing training and support

To maintain compliance with GPhC guidelines and ensure the highest standards of patient care, ongoing training and support for pharmacy staff are essential. Pharmacies should be using existing tools to risk assess the services they offer and ensure that they are appropriately indemnified. They should invest in staff training sessions that cover the best practices for prescription review and put in systems to ensure effective communication with prescribers. It may be that after considering all the above that you decide that it is in your overall best interest not to sign on the dotted line.

Conclusion

Collaborating with prescribing clinics can be an appealing arrangement for pharmacy businesses. However, these partnerships also come with significant responsibilities which should not be underestimated. It is vital for pharmacies to remain vigilant, proactive, and work with others to navigate these challenges successfully.

Author 

Shahzad Ahmad, MRPharmS, MFCI
Clinical Lead/Clinical Safety Officer/ Regulatory Consultant/ Healthcare Consultant – My Pharmacy Standards